9911796707
TMI Blog2018 (1) TMI 1236X X X X Extracts X X X X X X X X Extracts X X X X ..... Ken-Crest Global High School”, Karimnagar. Further, in the proceedings dated 17.12.2011, in the subject portion itself, the school is referred to as Ken-Crest International School. Therefore, there is no difference in the schools, which have been approved and the schools run by the assessee. Further, the CCIT, Hyderabad-3, vide order dated 27.09.2013, has granted the assessee; the registration u/s 10(23)(C)(vi) which goes to prove that the Revenue is satisfied about the assessee carrying on the activities exclusively for educational purposes which is a charitable activity. Therefore, the assessee is eligible for registration u/s 12AA and the reasons mentioned by the DIT (E) are not sustainable. As regards the condition that the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nal institutions i.e. Ken-Crest International School and Ken Crest Global School in Karimnagar Dist. He consider the contentions of the assessee that the Ken- Crest Global School was commenced in the year 1998-99 and is situated at Jyothinagar, Karimnagar, whereas the Ken-Crest International School was started in the year 2011-12 situated in Rangaraopalle Village, Gandadhara Mandal, Karimnagar Distt. He observed that the District Educational Officer, Karimnagar District and Regional Jt. Director of School Education, Warangal vide their separate proceedings have accorded recognition to such educational institutions. He perused the copies of such proceedings dated 18.3.2013 and 12.1.2008 respectively and noticed that the said authorities have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e India, he held that since the income of the society has not been applied only in India, the assessee is not eligible for registration u/s 12AA of the Act. He therefore, rejected the assessee s application u/s 12AA of the Act. Aggrieved, the assessee is in appeal before us by raising the following grounds of appeal: 1. The order of the learned Director of Income- Tax (Exemptions) is erroneous both on facts and in law. 2. The learned Director of Income-Tax (Exemptions) erred in refusing registration u/s 12AA of the Income-Tax Act to the appellant. 3. The learned Director of Income-Tax (Exemptions) ought to have seen that the appellant is carrying the charitable activities in accordance with the objects of the society. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he purpose of education. Therefore, the learned Counsel prayed that the assessee should be granted registration u/s 12AA of the Act. 6. Further, as regards the 2nd ground on which the DIT (E) has rejected the application, the learned Counsel for the assessee drew our attention to the provisions of section 12AA of the Act to demonstrate that there is no reference to the application of income in India in the said section. He submitted that there is a reference to the application of income in India in section 11 of the Act and therefore, after granting of registration u/s 12AA of the Act, the AO is required to examine the books of account for allowing exemption u/s 11 of the Act and the application of income would be relevant at that stage. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... High School , whereas in the body of the letter, the name is referred to as Ken-Crest Global High School , Karimnagar. Further, in the proceedings dated 17.12.2011, in the subject portion itself, the school is referred to as Ken-Crest International School. Therefore, there is no difference in the schools, which have been approved and the schools run by the assessee. Further, the CCIT, Hyderabad-3, vide order dated 27.09.2013, has granted the assessee; the registration u/s 10(23)(C)(vi) of the I.T. Act, which goes to prove that the Revenue is satisfied about the assessee carrying on the activities exclusively for educational purposes which is a charitable activity. Therefore, we are of the opinion that the assessee is eligible for registrat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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